Notice 2022-21, 2022-2023 Priority Guidance Plan Submission
132 Pages Posted: 9 Jun 2022
Date Written: May 26, 2022
This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.
Much of the submission concerns sourcing and effectively connected income rules. It also covers the existence of unanticipated partnerships among an MNC's group members that conduct joint business activities. Regarding subpart F, it makes suggestions concerning the manufacturing branch rule. Finally, it includes suggestions regarding the manner in which tax treaties should or should not apply to certain hybrid entities and how cost sharing agreements should be administered under Rev Proc 2015-41.
Keywords: ECI, Effectively Connected Income, Tax Treaties, Source of Income, Transfer Pricing, §482, Partnership, Check-the-Box, Entity Classification Rules, Subpart F, Branch Rule, CSA, cost sharing agreement, section 482
JEL Classification: H21, H25, K34, E62
Suggested Citation: Suggested Citation